Anti-Corruption & FCPA

Pamir provides strategic planning and implementation support for corruption prevention and response programs to ensure compliance with the US Foreign Corruption Practices Act (“FCPA”) and similar international corruption laws and regulations adapted to local legal and market realities.

We provide the following services:

Comprehensive Institutional Anti-Corruption Programs

We work closely with company executives, general counsel and compliance officers to develop holistic anti-corruption programs that implement recognized global best practices adapted to local legal and market realities in China and Taiwan including:

Home-Country Anti-Corruption Law Compliance Programs (conforming China/Taiwan practices with Home Country Laws and regulations)

Corruption Prevention Programs and Training

Crisis Response Services

Third Party Compliance Programs (Including Partners, Distributors, Suppliers and Others)

Programs to Prevent Leakage of Proprietary Trade Secrets/IP/Know-How by Company Employees to Third Parties

M&A/Transactions

Partner selection is the single most important anti-corruption decision any organization will make in China or Taiwan. We help clients screen the backgrounds and previous activities of potential acquisition targets, joint venture partners or key supply chain partners to reduce the risk that their past or current activities become a liability for their organization. Our services include:

Phase-One Corruption Due Diligence Programs. We advocate a streamlined two-step due diligence process. Phase one consists of an initial corruption screening of the target/partner and phase two consists of traditional legal and financial due diligence only if preliminary corruption due diligence is satisfactorily completed.

Risk Assessment Reports

Partner/Third Party Vendor Bona Fides Checks

Guanxi Mapping and Business Ecosystem Mapping Programs

Background Checks on Companies

Background Checks on Individuals including PRC Official Records Search, employment history verification, criminal records, official labor bureau and political party files as permitted by law.

Crisis Response & Investigations

We help clients to conduct in-depth investigations in response to internal or external allegations of embezzlement, kickbacks, commercial bribery and government bribery. We may facilitate working relationships with law enforcement agencies at the national and local levels. Our services include: